In compliance with applicable laws, this notice is to provide you with information about Personal Information we process, the rights you can exercise with regard to Personal Information we process, the periods for which Personal Information will be stored and the persons and entities with which we may share Personal Information.
Personal Information is information about you that makes you personally identifiable. This includes, without limitation, your name, contact information such as your address, e-mail address and phone number, date and place of birth, gender, country, as well as your social security number, assets, income, investment experience or any other identifying information you may send us in your interactions with us. We may also collect business information such as your job function and title, department, organization name and location.
If you are an investor or prospective investor, we collect Personal Information about you from the following sources:
If you are an investor, we will process your Personal Information for one or more of the following purposes and on the following legal grounds:
to perform services on behalf of First Look funds or to take steps at your request prior to entering into a contract with you, such as to provide requested information about our services, to facilitate the opening of your account with us, and for the management and administration of your holdings on an on-going basis to the extent that doing so is necessary, including, without limitation, the processing of redemptions, conversions, transfers, additional subscription requests, the payment of distributions and to keep you updated in relation to your investments; to carry out anti-money laundering checks and related actions which we consider appropriate to meet any legal, regulatory or judicial obligations imposed on us or in relation to the processing of data in the public interest or in pursuit of our legitimate interests in relation to the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis, in accordance with our and (if applicable) Third Parties' (as defined below) anti-money laundering procedures; to report tax-related information to tax authorities in order to comply with any legal, regulatory or judicial obligations; to engage in, monitor and record telephone calls and electronic communications for our legitimate interest of: (i) processing and verification of instructions; (ii) investigation and fraud prevention purposes; (iii) crime detection, prevention, investigation and prosecution; (iv) enforcing or defending us and our affiliates, ourselves or through Third Parties to whom we may delegate such responsibilities or rights in order to comply with any legal, regulatory or judicial obligation imposed on us; or (v) where the processing is in the public interest; to disclose information to Third Parties (as defined below) and parties such as other service providers to us, regulatory authorities and technology providers in order to pursue our legitimate interest to comply with any legal or regulatory obligation, court order or judicial request imposed on us; to engage in, monitor and record telephone calls for quality, business analysis, training and related purposes in order to pursue our legitimate interests to improve service delivery; to pursue our legitimate interest of improving our services to you, providing you with investment services and information relating to investment services, making our procedures more efficient, or implementing security measures; to update and maintain records and fee calculations to meet legal, regulatory or judicial obligations and to retain anti-money laundering and other records.
We do not disclose any Personal Information we collect, as described above, about our current or former investors to anyone other than to administrators, custodians, banks and service providers (including but not limited to our IT service providers, email archivists and CRM system providers) in connection with the administration, processing and servicing of customer accounts or to our accountants, attorneys and auditors (all such persons, collectively, “Third Parties”), or otherwise as required by law.
If you are not an investor, we collect Personal Information about you on the following occasions:
In this case, we will process your Personal Information for one or more of the following purposes and on the following legal grounds:
We may disclose your Personal Information to third parties, such as service providers, business sponsors and partners, when and to the extent necessary for the purposes above. Any such third party will not be allowed to further disclose your Personal Information, save where otherwise required or authorized by law.
Irrespective of whether you are or not an investor, we restrict access to Personal Information we collect about you to our personnel who need to know that information for the purposes above and who are subject to appropriate confidentiality obligations, or who are bound to confidentiality by statutory obligations.
You have the right to receive confirmation from us of whether or not we are processing your Personal Information and, if so, to obtain a copy of that Personal Information, as provided for by applicable law. You also have the right to obtain the rectification of inaccurate Personal Information without undue delay.
Your Personal Information will be retained for the time necessary in relation to the purpose(s) for which such information is processed. For example, we may retain limited amounts of your Personal Information to ensure compliance with a legal obligation to which we are subject or to market specific products and services. If you are an investor, your Personal Information will be processed for as long as you remain an investor with us, and when you are no longer an investor, we will continue to process your Personal Information which has a minimal privacy impact for the time which is necessary in relation to the purpose(s) for which such information is processed.
Depending on the legal regime applicable to you, you may also have specific additional rights regarding your Personal Information. Please contact our Privacy Team if you wish to exercise any of the following rights:
You also have the right to lodge a complaint with our Privacy Team or a supervisory authority if you believe our processing of Personal Information infringes applicable data protection laws.
We have mechanisms and procedures designed to ensure that, in case of a data breach (i.e. the unauthorized access, use, disclosure, acquisition, destruction or alteration, misuse, damage or accidental loss of Personal Information): we follow robust breach detection, investigation and internal reporting procedures; where required by law, we notify the relevant supervisory authority of a data breach in accordance with the timing and modalities envisaged in applicable law; where required by law, we inform you of any data breach in accordance with the timing and modalities envisaged in applicable law; and we keep records of any data breaches.
Should any changes be made to our privacy notice, for example because we begin processing data for a new purpose, a new privacy notice, specifically devoted to the change(s), will be delivered.
For any questions, requests or complaints concerning your Personal Information, including for any requests relating to your rights as discussed above, you can contact our Privacy Team at firstname.lastname@example.org